IR 05000352/1985035

Insp Rept 50-352/85-35 on 850811-23.No Violations Noted. Major Areas Inspected:Startup Program During Test Condition TC-1,including Startup Test Procedure Review,Witnessing, Results Evaluation & Plateau Review

ML20138B778
Person / Time
Site:	Limerick
Issue date:	10/04/1985
From:	Blumberg N, Eselgroth P, Florek D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20138B731	List: IR 05000352/1985035 ML20138B727
References
50-352-85-35, NUDOCS 8510220017
Download: ML20138B778 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-35 Docket N License No. NPF-39 Priority -- Category C Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, PA 19101 Facility Name: Limerick Nuclear Generation Station Inspection At: Limerick, Pennsylvania Inspection Conducted: August 1-23, 1985 Inspectors: .

O. Flor Lead Reacto Engineer

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r s "l/ k WBl~u;nberg, Lept Reactor Enginpr date Approved b : og // / 89 F. Eselgrott}ffhief, Test Program Section date'

Inspection Summary: Inspection on August 11-23, 1985 (Inspection Report No. 50-352/86-35}

Areas Inspected: Routine, onsite unannounced inspection of the startup prcgram during test condition TC-1 including startup test procedure review, startup test witnessing, startup test results evaluation and startup test plateau review; independent measurements, calculations and verifications; QA/QC Interfaces and tours of the facility. The inspection involved 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> onsite by two region based inspector Results: No violations were identifie Note: Acreayms and initialisms used and not defined herein, are defined in NUREG-0%4, Rev. PDR ADOCK 0 85 h b2 PDR G

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DETAILS 1.0 Persons Contacted Philadelphia Electric Company and Contractors 0. Atkinson, Startup Test Coordinator

• P. Duca, Technical Engineer

• C. Endriss, Regulatory Engineer P. Fleckser, Startup Test Scheduler

• J. Franz, Superintendent of Operations

• S. Jenkins, Startup Test Program Supervisor G. Leitch, Plant Manager

• J. McElwain, QA Auditor W. Noll, Startup Test Coordinator

• R. Smith, QA Auditor U.S. Nuclear Regulatory Commission E. Kelly, Senior Resident Inspector

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• denotes those present at exit meeting on August 22, 1985.

2.0 Startup Program References

Regulatory Guide 1.68, Revision 2, " Initial Test Program for Water-Cooled Nuclear Power Reactors"-

ANSI 18.7 - 1976, " Administrative Controls.and Quality Assurance for the Operational Phase of Nuclear Power Plants"

Limerick Generating Station (LGS) Technical Specification

LGS Final Safety' Analysis Report

LGS Safety Evaluation Report

Nuclear Energy Business Operations (NEB 0) 23A1918,-Revision 0,.

" Limerick 1 and 2 Startup Test Specification"

LGS Startup Program Schedule

Administrative Procedure A-200, "Startup Test Procedure Format and Content"

Administrative Procedure A-201, "Startup Test Procedure Contr.ol"

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• Administrative Procedure A-202, "Startup Test Implementation"

• Administrative Procedure A-203, "Startup Test Program Personnel Training and Qualification" 2.1 Startup Test procedure Review Scope The 23 procedures listed in Appendix A were reviewed for administra-tive and technical adequacy. The attributes contained in Inspection Report No. 50-352/84-50 were utilized for this determinatio Discussion All procedures were found to satisfy the above attributes. However, several discussions were. held between the inspector and licensee regarding the procedures and the following results were obtaine *

Changes were made to STP-29.1 and 29.2 to specify three element feedwater control as a prerequisite as indicated in chapter 14 of the FSA * Response to NRC Question 640.25 indicated that a two recircula-tion pump trip would occur from full power. STP-30 two loop recirculation pump trip was planned to be conducted at less than full power but at near full recirculation flow. The licensee is revising the FSAR in accordance with the full power license re-quirement for changes in the startup program. Inspector review-ed associated 10.CFR 50.59 review results, and no unacceptable conditions were note * The inspector review and discussion of STP-31.1 resulted in the following. The licensee will not pre-lube the diesel generator prior to conducting the loss of offsite power test if this acti-vity, which normally will not occur for emergency diesel genera-tor starts, will increase the diesel generator start probability for_this test. The licensee will revise the procedure to assure that the following safety functions: reactor protection system, main steam isolation valve closure, high pressure coolant injec-tion system initiation and reactor core isolation cooling system initiation, will only be manually initiated if the automatic actions fail to be performe Findings No' violations were noted.

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2.2 Test Witnessing i

Scope The inspector witnessed all or portions of the following startup tests in progress to assess the adequacy of the test, the overall >

performance by licensee personnel, and the adequacy of test results; ,

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• STP 11.2, LPRM Calibration w/o Process Computer i * STP 14.7, RCIC Survillance Tests CST to CST STP 14.8, RCIC Endurance-Run

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I * STP 14.9, (RCIC) Loss of AC Power [

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During the performance of the above tests, the following areas were l verifie * Prerequisites and initial conditio , were me f

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• Test equipment was in calibration.

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* Procedures were correctly followe .

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All data were properly taken and analyzed.

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Test results were acceptabl '

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Personnel performing the tests were knowledgeable of the test l procedure.

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Procedure changes were obtained when require '

l Discussion

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The inspector witnessed the pulling of rods to raise the reactor power level above 5% power as allowed by the current full power license. The reactor mode switch was placed.from startup to run at

about 7% power for the first time. Plant power was ultimately raised to approximately 20% power, the top power level for test j condition (TC)-1.

I Power levels, which were adjusted with correction factors obtained during low power testing, indicated approximately 19% power.

However, the initial heat balance indicated actual power level was approximately 23% powe This heat balance was checked several times and reverified to be 23%. The discrepancy was attributed to feed-water heaters not in service.

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e The licensee first attempted to reduce power by placing the feedwater heaters in service. However, there was difficulty in plac' inh all the feedwater heater strings in service as these heaters were being placed in service for the first time. Eventually the power was reduced to 16% indicated by driving in control rod Subsequent heat balances indicated actual power to now be 19%. The Senior Resident Inspector independently calculated the heat balance using the licensee's procedure and verified the power to be approximately 19% power. Power remained at this level for the remainder of TC-1 testin On August 16, 1985, Federal Appeals Court stayed the NRC's authorization of a full power license for Limerick Generating Station. Power level was reduced to 5% or less pending further court action. On August 21, 1985, the court lifted the stay and licensee resumed normal testing operation Prior to. entering Operational Condition (OPCON)-1, all surveillance tests required for OPCON-1 must be completed. The RCIC system did not pass its operational surveillance test as its turbine throttle control valve was not operating properly. The inspector witnessed a portion of the maintenance troubleshooting of this problem, including local RCIC turbine throttle control in the RCIC Pump Roo The licensee at first thought the problem may have been air in the throttle control oil lines. However, the venting of the lines showed no air present. The inspector observed venting of the oil lines and the attempted control of the RCIC turbine from the Control Room. The turbine throttle would not close on command from the Control Roo The licensee eventually found the problem to be a minor misalignment of the throttle control valve servo mechanism which prevented the valve from shutting remotely. (The valve would open properly)

Three alignment shims were inserted into the servo mating flange which corrected the problem and the RCIC steam throttle valve thus functioned properly. The inspector expressed a concern that the shims may constitute a system modification. On a later date the inspector verified shim installation The shims were three thousandths of'an inch thick. Based on visual observation the

. inspector determined that installation of the shims would not effect seismic qualification, system operability, nor require a drawing change and did not constitute a system modificatio Findings No violations were note ,

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i 2.3 Test Results Evaluation l t

Scope  ;

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The startup tests listed in the discussion section below were i-reviewed for the attributes identified in inspection report 50-352/84-70, Section i

Discussions i

Except as noted below all startup test results were found to meet  !

the attributes referenced above. The inspector also assessed that [

previously reviewed startup tests STP-15.1-1, STP-15.2-7 and  :

STP-26.1-1 were reviewed and accepted by management. A summary of  :?

each test follow !

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Ali data were collected. All acceptance criteria were satisfied. Management approved the tes STP- " Reference Leg Temp Comparison", Revision 1, Test r implemented August 15, 198 Management reviewed and accepted tests result f

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STP-12.2 " Low Power APRM Calibration", Revision 1 Test implemented  !

August 16, 198 I t

! APRM settings were as follows:

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C .~ 2 .  ! .3 2 .8 2 i F.

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i Acceptance criteria were satisfie i

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STP-14.4 " Controller Optimization during RPV Injection at Rated Pressure", Revision 0, Test Implemented February 27, 198 RCIC achieved rated flow in the vessel in approximately 19 seconds and did not trip in the final data set thus i satisfying the acceptance criteria. Three exceptions were noted and processed in accordance with the administrative  ;

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1 STP-14.5 " Stability Check CST to RPV at 150 PSIG", Revision 1 Test Implemented March 1, 198 All data were collected. RCIC schieved rated flow, in approximately 6 seconds. All acceptance criteria were satisfie STP-15.3 "HPCI Stability Check CST to CST at 200 PSIG," Revision 1, Test implemented February 20, 198 *

[ HPCI achieved 5600 gpm in approximately 20 seconds, did not trip or isolate, thus satisfying the level 1 test criteria. One test exception was identified and processed in accordance with the administrative procedur STP-15.7 "HPCI Endurance Run", Revision 0, test implemented s

January 16, 198 ,

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HPCI was operated for 75 minutes with the pump and turbine

oil temperatures stabilized and thus satisfied the acceptance criteri STP-16.1 " Minimum Recirculation Pump Speed Determination".

, No acceptance criteria were verified as a result of this test however, the electrical low speed limiters were set at least 1% above the minimum speed identified during

'this test as required.

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STP-17.1 " Measured Pipe Displacements" Revision 1 Plant Condition Test Implemented 550 F January 11, 1985 Cooldown March 3, 1985

Licensee accepted test results. Test exceptions were i

processed in accordance with the admiriistrative procedure.

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STP-17.4 " Visual Pipe Inspection Main Steam Inside Drywell and Reactor Recirculation" Plant Conditions Test Implemented {

Rated Temperature January 28, 1985  !

Cooldown March 5, 1985  :

Licensee accepted test results. An exception against' i

. acceptance criteria was noted and processed in accordance ;

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STP-19.1 " Backup Core Limit Estimate (BUCLE) Calculation", Rev-1 Test Implemented August 16, 198 Acceptance criteria were satisfie STP-22.3 " Pressure Regulator Response - Bypass Valve Open", Revision 1, Test Implemented August 13, 198 No divergent oscillations were noted for 10 psig step changes or failed regulator test STP-23.3 "Feedwater System Startup Controller Level Step" Revision 0, Test implemented August 13, 198 Transient oscillations did not diverge. A test exception was prepared for not meeting damping criteri It was

accepted for current plant condition STP-25.1 "MSIV Functional Test", Revision 0, Test implemented February 26, 198 .

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MSIV stroke times ranged from 3.33-4.04 seconds thus satisfying the acceptance criteri .4 Startup Test Plateau Review Scope The inspector witnessed portions of licensee PORC Meetings 85-73 on

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August 19, 1985,-and 85-74 on August 20, 1985 to ascertain whether the licensee is performing an adequate evaluation of test results, to evaluate the adequacy of the licensee's administrative practices in maintaining proper test discipline concerning test execution, test 4 alteration, and test records and to ascertain whether the licensee is following their procedures for review, evaluation, and acceptance of test result Discussion The PORC meeting reviewed various startup test results test changes and test exception reports. The licensee evaluation was comprehensive and thorough. The licensee was observed to follow the administrative procedures for implementation of the startup progra Findings

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No violations were identifie __

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3.0 Independent Measurements, Calculations and Verifications During this inspection the inspector performed the following independent measurements, calculations, and verifications. All items identified below were accomplished on a sampling basis:

• The inspector witnessed testing of the RCIC system for TC-1, STP's 14.7, 14.8, and 14.9 which were performed concurrently. These tests included a RCIC cold quick start (the system must not have had steam for .72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) condensate storage tank (CST) to CST; a second quick start (hot) to adjust RCIC discharge pressure; two hot quick starts to'the reactor pressure vessel; a RCIC endurance run in excess of two hours; and operation of RCIC system without A/C power. During performance of these tests the inspector 11 dependently verified by observation of plant instruments that RCIC achieved proper flow rates and proper discharge pressure;.that RCIC pump suction and discharge valves operated properly;'that RCIC steam flow valves operated properly; that RCIC pump room temperature limits were not exceeded; and that battery voltages did not go below minimum specified by the procedure. In addition, the inspector independently timed RCIC quick starts to verify that RCIC achieved full flow in less than 30 second *

LPRM calibrations were performed during this inspection. On a sampling basis, the inspector verified proper LPRM settings were being made during LPRM adjustments. The inspector also performed independent calculations of application of the gain adjustment factor for the proper LPRM setting * Independent verification was performed on the electrical breaker alignment in the loss of offsite power test procedure for correct position to conduct the test as described in the FSA *

The inspector also independently verified several of the analysis steps in completed test procedures using the data collected during the test as part of the test results evaluation .0 QA/QC Interfaces There is at least one QC inspector per shift assigned full time to cover startup testing. On back shifts there is at least one other QC inspector assigned to cover other work who can be used to aid the startup QC inspector when conditions warrant. Witness points are assigned to the QC inspector by the QC Section and are placed in the QC copy of the test procedure. Test personnel are not aware of the specific witness points and it is up to the QC inspector to be knowledgeable of the test and to be

present for the witness points. In addition, tests have a prerequisite verification that QC has been notified prior to the start of the tests.

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ID The inspector observed the presence of a QC inspector during each shift and discussed QC interface with testing with two QC inspectors. During RCIC testing, a QC inspector was observed performing witness point inspections as specified by the QC section. A second backup inspector was called to support their testing coverage during the RCIC tests. QC inspectors independently veri'ied data being taken, proper performance of procedure steps, and that p. , requisites were me .0 Plant Tours The inspector made several tours of the facility during the course of the inspection including the reactor building, turbine building, control structure and control room. No unacceptable conditions were note .0 Exit Interview An exit meeting was held on August 22, 1985, to discuss the inspection findings as detailed in this report. (See paragraph 1 for attendees).

At no time during the inspection did the inspector provide written inspection findings to the licensee. At the exit, the licensee did not identify any proprietary material that was contained within the scope of the inspection. Subsequent to the exit meeting the inspector returned to the site'on August 23, 1985 to witness a scheduled test. The test was delayed beyond the end of this. repor :

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APPENDIX A STARTUP TEST PROCEDURE REVIEW

! STP-23.7 " Maximum Feedwater Runout Capability", Revision 0, dated j October 15, 1984 STP-27.0 " Main Turbine Trip", Revision 0, dated April 9, 1985

, STP-27.1 Turbine Trip Utilizing Bypass Capacity", Revision 0, dated April 9, 1985 STP-27.2 " Bypass Valve Capacity Check", Revision 0, dated April 9, 1985

STP-27.3 " Turbine Trip at TC-3", Revision 0, dated April 9, 1985 STP-27.4 " Turbine Trip", Revision 0, dated April 9, 1985-

" STP-28.0 " Shutdown from Outside Control Room", Revision 1, dated August 7, 1985 STP-28.1 " Reactor Shutdown to Hot Standby Demonstration", Revision 1, dated August 7, 1985 STP-28,2 " Reactor Cooldown Demonstration", Revision 1, dated August 7, 1985 10. STP-29.0 " Recirculation Flow Control' System", Rnvision 0, dated September 19, 1984 11. STP-29.1 " Local Manual Recirculation Flow Control", Revision 0, dated

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12. STP-29.2 " Master Manual Recirculation Flow Control", Revision 0, dated j , September 19, 1984

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13. STP-30.0 " Recirculation System", Revision 0, dated June 1, 1984

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14. DSTP-30.1 " Recirculation System One Pump Trip", Revision 0, dated June 1, 1984 15. STP-30.2 " Recirculation Pump Trip (RPT) of Two Pumps", Revision 0, dated June 1, 1984

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APPENDIX A-2-1 STP-30.3 " Recirculation System Performance", Revision 1, dated August 7, 1985 17. STP-30.4 " Recirculation Pump Runback", Revision 0, dated June 1, 1984 18. STP-30.5 " Recirculation System Flow Calibration", Revision 0, dated June 1, 1984 19. STP-31.0 " Loss of Turbine Generator and Offsite Power", Revision 0, dated October 12, 1984 2 STP-31.1 " Loss of Turbine Generator and Offsite Power", Revision 0, dated June 20, 1985 21. STP-35.0 " Recirculation System Flow Calibration", Revision 0, dated

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September 19, 1984 22. STP-35.1 " Recirculation System Flow Calibration", Revision 0, dated September 19, 1984 2 STP-35.2 " Recirculation System Flow Limit Adjustment", Revision 0, dated September 19, 1985

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